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EUDR geolocation verification and satellite monitoring

EUDR Geolocation Verification: How Your Coordinates Are Actually Checked

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Collecting geolocation data from your suppliers is only half the job. The harder question - the one that determines whether your shipment clears or gets held - is whether that data will survive verification. Coordinates that look fine in a spreadsheet can fail the moment they're loaded into the EU Information System and cross-referenced against satellite imagery. This guide explains exactly how that verification works, what regulators are looking for, and how to catch problems before they catch you.


What "Verified" Actually Means Under the EUDR

The EUDR doesn't ask you to self-certify that your supply is deforestation-free and leave it at that. It requires you to submit geolocation data that can be independently cross-referenced against earth-observation data - specifically the EU's Copernicus satellite programme - to test whether the stated production area was subject to deforestation after 31 December 2020.

That's the mechanism. A coordinate or polygon boundary is submitted to the Information System. Regulators and competent authorities can then overlay that geometry against satellite-derived forest-cover data to check whether the land changed from forest to agricultural use after the cut-off date. If your coordinates are imprecise, malformed, or simply wrong, that cross-reference cannot be performed - and your due diligence statement is, at best, unverifiable and, at worst, rejected.

The EUDR requires geolocation data to be cross-referenced against the EU's Copernicus satellite database to verify that land was not subject to deforestation after 31 December 2020.

This is why the quality of geolocation data matters so much more than most operators initially expect. It's not a filing formality - it's the evidentiary foundation of your deforestation-free claim.

Already familiar with the cut-off date and what "deforestation-free" means? Our EUDR cut-off date explainer covers the 31 December 2020 baseline in detail. This guide focuses on what happens to your coordinates after you submit them.


The Precision Requirement: Why Six Decimal Places Is Non-Negotiable

Every coordinate submitted under the EUDR must be recorded with at least six decimal digits of precision in both latitude and longitude.

Six decimal places in decimal degrees corresponds to a ground resolution of roughly 11 centimetres. That level of precision is what allows a coordinate to be unambiguously placed on a satellite image and matched to a specific parcel of land. Fewer decimal places introduce positional uncertainty that can shift a point by tens or hundreds of metres - enough to land it on a neighbouring plot, a road, or even in the sea.

Common precision failures include:

  • Coordinates rounded to 2-4 decimal places - often the result of manual data entry or export from older GIS tools
  • Coordinates in degrees-minutes-seconds (DMS) format that were converted incorrectly to decimal degrees
  • Truncated values where trailing zeros were dropped during spreadsheet formatting

The fix is straightforward: validate every coordinate in your dataset before submission and confirm that each value carries at least six digits after the decimal point.


Point vs. Polygon: The 4-Hectare Rule Explained

The EUDR draws a clear line based on plot size, and getting this wrong is one of the most common causes of rejected declarations.

For plots smaller than 4 hectares, a single latitude/longitude point is permitted. For plots of 4 hectares or more, a polygon describing the perimeter of the production area is required.

Here's what that means in practice:

ScenarioPlot SizeRequired FormatWhat It Must Contain
Small cocoa farm< 4 haSingle pointOne lat/lon pair, ≥ 6 decimal places
Medium rubber plantation≥ 4 haPolygonMultiple coordinate pairs tracing the plot perimeter, closed shape, ≥ 6 decimal places
Large soy field≥ 4 haPolygonMultiple coordinate pairs tracing the plot perimeter, closed shape, ≥ 6 decimal places
Cattle (any size)N/AEstablishment-levelCattle follow their own establishment logic — not the standard 4 ha threshold

Why does the polygon requirement exist? A single point tells regulators roughly where a farm is. It doesn't show how big the farm is, what's inside its boundaries, or whether any part of it overlaps with a deforested area. A polygon, by contrast, allows satellite systems to assess the entire production area - not just a centre point - against forest-cover data. For larger plots, a point is simply not sufficient to make a defensible deforestation-free determination.

Plots of 4 hectares or more must be described with a polygon boundary in GeoJSON format for submission to the EU Information System.

A note on GeoJSON: The EU Information System accepts geolocation data in GeoJSON format using the WGS84 (EPSG:4326) coordinate reference system. Any other format - PDF, CSV, KML submitted incorrectly - will be rejected outright. The GeoJSON file must be structurally valid: polygons must be closed (first and last coordinate pairs must match), property names must be correctly spelled and cased, and coordinate values must be numbers, not strings.


How Satellite Cross-Checking Works

Once your geolocation data is in the system, the verification mechanism works like this:

Geometry is validated
The Information System checks that the submitted GeoJSON is structurally valid — correct format, closed polygons, coordinates within valid ranges (lat −90/+90, lon −180/+180), no duplicate or self-intersecting boundaries.
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Plot is located on the map
The coordinate or polygon is placed on a geospatial reference layer. At this stage, obvious errors become visible: coordinates in the ocean, points that fall in a city rather than a farm, or polygons that overlap with other declared plots.
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Forest cover is assessed at the cut-off date
The plot geometry is overlaid against satellite-derived forest-cover data — including Copernicus Sentinel-2 imagery — to establish the land's status as of 31 December 2020. This is the baseline against which deforestation is measured.
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Change detection is run post-cut-off
Satellite time-series data is used to detect whether any forest clearing occurred on or within the plot boundary after 31 December 2020. If clearing is detected, the plot cannot be considered deforestation-free under the EUDR.
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Risk determination is made
Based on the above, the plot is assessed as presenting negligible risk (deforestation-free) or non-negligible risk. A non-negligible risk finding means the due diligence statement cannot be submitted — or, if already submitted, may be flagged for inspection.

The Copernicus programme's Sentinel-2 satellites provide imagery at 10-metre resolution, refreshed regularly. Plot coordinates that are imprecise or misplaced can cause the wrong land area to be assessed - which is why precision and correct placement are prerequisites for a valid deforestation-free determination, not just administrative niceties.


Common Data-Quality Failures That Get Shipments Held

Most geolocation rejections aren't caused by actual deforestation. They're caused by data quality problems that make verification impossible. Here are the most frequent failure modes:

Structural / format failures

  • GeoJSON polygon is not closed (first and last coordinate pairs don't match)
  • Wrong coordinate reference system (not WGS84/EPSG:4326)
  • Property names misspelled or incorrectly cased (e.g. "productionplace" instead of "ProductionPlace")
  • Numeric values stored as strings ("Area": "3" instead of "Area": 3)
  • File exceeds system size limits or is password-protected

Positional failures

  • Coordinates placed in the sea, in a city, or on a road rather than on the actual farm
  • Point coordinates that represent a warehouse or processing facility, not the production plot
  • Polygon boundaries that don't match the actual field (e.g. traced from an outdated map)
  • Overlapping polygons from the same or different suppliers claiming the same land

Precision failures

  • Fewer than six decimal places in latitude or longitude
  • Coordinates rounded during export from a spreadsheet or ERP system

Logical failures

  • Coordinates that don't match the claimed crop (e.g. a point placed in a known rubber-growing region submitted for a coffee declaration)
  • Outdated coordinates reused from a previous season when plot boundaries have changed
  • A single polygon used to represent multiple non-contiguous parcels (each parcel needs its own geometry)
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Incomplete or improperly formatted GeoJSON files are among the top reasons for Due Diligence Statement (DDS) rejection. A single structural error — a missing closing coordinate, a wrong property name — can make an entire submission unreadable to the Information System, holding up a shipment regardless of whether the underlying land is genuinely deforestation-free.


Self-Verification Before You Submit

The most effective way to avoid a rejection is to run your own verification pass before the data goes anywhere near the Information System. Think of it as a pre-flight check.

Beyond the checklist, the single most useful manual step is to load your GeoJSON file into a free viewer such as geojson.io and visually inspect every plot. If a polygon doesn't display correctly in a standard GIS viewer, it won't work in the EUDR system either. Look for:

  • Points that fall in the ocean or in obviously wrong locations
  • Polygons that are far larger or smaller than the declared plot size
  • Overlapping boundaries between different supplier plots

For operators managing large numbers of plots, automated geometry validation - checking for closed polygons, valid coordinate ranges, and duplicate geometries - is essential. Manual review at scale is too slow and too error-prone.


How Inspection Rates Are Determined: The Country Tier System

Not every operator faces the same level of scrutiny. The EUDR uses a risk-based inspection model tied directly to the country benchmarking system. Competent authorities in each EU Member State are required to inspect a minimum percentage of operators (and volume) each year, based on the risk tier of the country of origin:

Competent authorities must inspect at least 9% of operators sourcing from high-risk countries, 3% from standard-risk countries, and 1% from low-risk countries each year.

EUDR Minimum Annual Inspection Rates by Country Risk Tier

These are minimum thresholds. Competent authorities can - and do - exceed them, particularly when substantiated concerns are raised by NGOs, whistleblowers, or other third parties. A watchdog group submitting satellite imagery showing land clearing on a supplier farm can trigger an investigation entirely outside the regular inspection cycle.

Where do most supply chains sit? As of the first official benchmarking published on 22 May 2025:

  • Only four countries are classified as high risk: Belarus, Myanmar, North Korea, and Russia.
  • More than 140 countries are classified as low risk, including all EU Member States, the UK, the US, Canada, China, Japan, and Australia.
  • Major commodity-producing nations - Brazil, Indonesia, Malaysia, Côte d'Ivoire, Ghana - are standard risk by default.

That means the vast majority of operators importing cocoa, palm oil, soy, rubber, and coffee are in the 3% standard-risk inspection band. That's not a trivial number: roughly one in thirty operators will be checked each year, and the TRACES system is designed to flag operators with incomplete or inconsistent filings for prioritised review.

The 2026 benchmarking review: The first classification is not permanent. The Commission planned a first review of country tiers in 2026, drawing on updated FAO Global Forest Resources Assessment (FRA) data. Tiers can move - and if a country you source from shifts from low to standard risk, your inspection exposure triples overnight. Our country risk list is updated as classifications change.

Sourcing from standard-risk origins like Brazil or Indonesia? The 3% inspection rate means your geolocation data quality is your primary defence. Weak data doesn't just risk a rejection - it flags your filing for closer scrutiny.


The July 2026 Information System Update: What Changed

On 13 July 2026, the European Commission adopted an Implementing Act setting out the technical rules for the EUDR Information System - the platform where geolocation data and due diligence statements are submitted. This is directly relevant to anyone building or updating their submission workflow.

Key changes from the July 2026 Implementing Act:

  • Updated API specifications for operators using automated system-to-system integration to submit due diligence statements at volume. If your compliance workflow relies on API submission, your development team should check the updated specifications on CIRCABC.
  • Simplified declarations for micro and small primary operators, reducing the submission burden for smaller producers.
  • Grouping functionality allowing certain due diligence statements to be grouped, reducing total submission volume.
  • Contingency measures for unplanned system unavailability - the regulation now requires the Commission to publish contingency procedures, including a reference number operators can use when the system is down.

The Information System reopened at the end of June 2026 following technical updates. The Commission committed to continuing documentation updates and offering company training sessions from late July 2026 onwards. Additional functionalities are expected to roll out over the summer.

On 13 July 2026, the European Commission adopted Implementing Regulation (EU) 2026/1565, setting out the technical rules for the EUDR Information System, including updated API specifications and simplified declarations for micro and small primary operators.

For operators building API integrations, the acceptance (training) server is available for testing before going live on the production server. Submissions on the acceptance server have no legal value - use it to validate your GeoJSON structure and submission workflow before enforcement begins.

For a full breakdown of what changed in the Information System relaunch, see our Information System relaunch guide.


Records: The Five-Year Retention Requirement

Geolocation data doesn't just need to be accurate at the point of submission - it needs to be retained. All EUDR compliance records, including geolocation files, risk assessments, and supplier details, must be retained for at least five years after the product is placed on the market.

Competent authorities can request this documentation at any point during that window. If you cannot produce the geolocation data that underpinned a due diligence statement - because it was stored in a format that's since been deprecated, or because the supplier relationship ended - you have a compliance gap even if the original submission was accepted.

Store GeoJSON files in a durable, accessible format. Link each file to the specific due diligence statement it supports. And make sure your retention system survives supplier offboarding.


Pre-Submission Verification Checklist

Before submitting any due diligence statement that includes geolocation data, work through this checklist:

Precision & format

  • All coordinates have at least six decimal places in both latitude and longitude
  • Coordinates are in decimal degrees (not degrees-minutes-seconds)
  • File is valid GeoJSON in WGS84 / EPSG:4326 projection
  • File is not password-protected and is under the system size limit

Geometry

  • All polygons are closed (first and last coordinate pairs are identical)
  • No self-intersecting polygon boundaries
  • Each separate parcel has its own polygon - no single polygon covering multiple non-contiguous plots
  • File displays correctly in geojson.io or equivalent GIS viewer

Positional plausibility

  • All points/polygons fall on land, not in the sea or on a body of water
  • Coordinates match the claimed country and crop type
  • No coordinates placed on roads, warehouses, processing facilities, or urban areas
  • No overlapping boundaries between different supplier plots

Plot size rule

  • Plots under 4 ha: single point is acceptable (but polygon is always more defensible)
  • Plots 4 ha or more: polygon is mandatory - no single-point submissions
  • Cattle declarations use establishment-level geolocation, not the 4 ha threshold

Records

  • GeoJSON files are linked to the specific DDS they support
  • Files are stored in a format that will remain accessible for five years

FAQ

help_outlineCan I use a point for a plot that is exactly 4 hectares?expand_more

No. The threshold is plots smaller than 4 hectares. A plot of exactly 4 hectares requires a polygon. When in doubt, use a polygon — it is always more defensible and provides a better basis for satellite verification.

help_outlineWhat happens if my GeoJSON file has a structural error?expand_more

The Information System will reject the submission. Common structural errors include unclosed polygons (first and last coordinate pairs don't match), incorrect property name casing, and numeric values stored as strings. Validate your file in a GIS viewer like geojson.io before uploading — if it doesn't render correctly there, it won't work in the EUDR system.

help_outlineDoes a low-risk country classification mean my geolocation data won't be checked?expand_more

No. Low-risk status reduces the frequency of inspections (to a minimum of 1% of operators per year), but it does not remove the obligation to submit accurate geolocation data. You must still collect and submit coordinates for every production plot, and those submissions can still be selected for review.

help_outlineHow does Copernicus satellite data actually detect deforestation?expand_more

Copernicus Sentinel-2 satellites capture multispectral imagery at 10-metre resolution on a regular revisit cycle. By comparing imagery from before and after 31 December 2020, analysts and automated systems can detect changes in vegetation cover — specifically the conversion of forest to agricultural land. Your submitted plot coordinates are overlaid on this imagery to determine whether the specific area you declared was affected.

help_outlineCan a third party trigger an inspection of my geolocation data outside the regular inspection cycle?expand_more

Yes. The EUDR includes a 'substantiated concerns' mechanism that allows NGOs, civil society organisations, or other parties to submit evidence of potential non-compliance. A credible concern — such as satellite imagery showing land clearing on a declared plot — can trigger a competent authority investigation regardless of whether your operator was selected in the regular risk-based inspection round.

help_outlineWhat format does the EUDR Information System accept for geolocation data?expand_more

GeoJSON is the required format, using the WGS84 (EPSG:4326) coordinate reference system. Other formats — including KML, Shapefile, or CSV — are not accepted by the system. Your GeoJSON must be structurally valid and meet the precision requirements (≥6 decimal places per coordinate).

help_outlineHow long do I need to keep geolocation records?expand_more

At least five years from the date the product was placed on the EU market. This includes the GeoJSON files, the risk assessment, and the due diligence statement itself. Competent authorities can request this documentation at any point during the retention window.


Get Ahead of Verification

The gap between "we collected coordinates" and "our data survives verification" is where most compliance problems live. Precision failures, wrong geometry types, and positional errors are all fixable - but only if you catch them before submission, not after a shipment is held.

Use our free EUDR Geolocation Tool to map and export plot coordinates in the correct GeoJSON format, and check our supplier data templates to make sure the data you're requesting from growers meets the format and precision requirements from the start.